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119 results for “transfer pricing”+ Section 148(1)clear

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Key Topics

Section 25096Addition to Income37Section 10(37)14Exemption13Capital Gains12Section 14810Section 2(24)(vi)8Section 488Section 2637

SRI. ELDHOSE K. VARGHESE,MUVATTUPUZHA vs. THEDCIT, ERNAKULAM

In the result, appeals for assessment year 2006-07 to 2008-09 and 2010-11 are allowed while the appeals of the assessee for assessment year 2009-10, 2011-12 and 2012-13 are partly allowed

ITA 261/COCH/2016[2006-07]Status: DisposedITAT Cochin03 Oct 2017AY 2006-07

Bench: Shri P. K. Bansal & Shri George George K.

Section 132Section 143(1)Section 143(2)Section 153ASection 153CSection 234A

148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person other than the person referred to in section 153A, then the books of account or documents or assets seized

Showing 1–20 of 119 · Page 1 of 6

Reassessment7
Section 143(3)6
Section 36(1)(viia)5

KERALA STATE CO-OPERATIVE BANK LTD,THIRUVANANTHAPURAM vs. DCIT,CIRCLE-1(1), THIRUVANANHAPURAM

ITA 171/COCH/2024[2018-2019]Status: DisposedITAT Cochin11 Dec 2024AY 2018-2019

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2018-19

For Appellant: Shri Dijo Mathew, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(2)Section 270ASection 270A(1)Section 270A(2)Section 36(1)(viia)Section 40

Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. (7) The penalty referred to in sub-section (1) shall be a sum equal

SHRI.PRAKASH R. NAIR,KOLLAM vs. DCIT, KOLLAM

In the result, the assessee’s appeal is partly allowed for statistical purposes

ITA 141/COCH/2021[2000-2001]Status: DisposedITAT Cochin17 Jan 2024AY 2000-2001

Bench: Shri Sanjay Arora & Shri Manomohan Dasprakash R. Nair Dy.Cit, Central Circle Prop. Dhanya Foods Kollam Kochuppilammoodu Vs. Kollam 691001 [Pan:Abfpn4424P] (Appellant) (Respondent)

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 143(1)Section 148(1)Section 271(1)(c)Section 274Section 80Section 801A(9)Section 80HSection 80I

148(1) was issued, which was responded to by filing a return of income on 06.06.2003 at Rs.19,30,992, i.e., at an increase of Rs.1,02,199, retaining deduction u/c. VI-A at Rs.4.15 crores, even as that u/s. 80HHC stands enhanced to Rs.471.53 lakhs. This variation was explained in the assessment proceedings as on account of omission

M/S.US TECHNOLOGY INTERNATIONAL P. LTD,TRIVANDRUM vs. THE JCIT, TRIVANDRUM

In the result, the appeal filed by the assessee is allowed

ITA 247/COCH/2017[2009-10]Status: DisposedITAT Cochin23 Jul 2018AY 2009-10

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.M.Raghunathan SFor Respondent: Sri.Santam Bose
Section 10ASection 10BSection 143(1)Section 143(3)Section 144CSection 263

transfer pricing adjustment in the draft assessment order. The final assessment order was passed on 26.04.2013. The assessee, however, claims that the final assessment order was not received by it. Thereafter reassessment notice was issued and orders u/s 143(3) r.w.s. 147 of the I.T.Act was passed on 27.03.2015. The Assessing Officer in the reassessment completed, disallowed the amount claimed

SRI.R. PRATAP,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 38/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

SRI.R.PRAKASH,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 43/COCH/2016[2011-12]Status: DisposedITAT Cochin03 Feb 2020AY 2011-12

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

SRI.R.PRAKASH,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 42/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

SRI.K.RAVINDRANATHAN NAIR,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 46/COCH/2016[2008-09]Status: DisposedITAT Cochin03 Feb 2020AY 2008-09

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

SRI.R. PRATAP,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 37/COCH/2016[2009-10]Status: DisposedITAT Cochin03 Feb 2020AY 2009-10

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

SRI.R. PRATAP,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 39/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

M/S. VIJAYALAXMICASHEW CO.,,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 49/COCH/2016[2011-12]Status: DisposedITAT Cochin03 Feb 2020AY 2011-12

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

SRI.R.PRAKASH,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 41/COCH/2016[2009-10]Status: DisposedITAT Cochin03 Feb 2020AY 2009-10

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

M/S. VIJAYALAXMICASHEW CO.,,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 47/COCH/2016[2008-09]Status: DisposedITAT Cochin03 Feb 2020AY 2008-09

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

SMT. T.C. USHA,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 45/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

SRI.R.PRAKASH,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 40/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

SMT. T.C. USHA,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 44/COCH/2016[2009-10]Status: DisposedITAT Cochin03 Feb 2020AY 2009-10

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

M/S. VIJAYALAXMICASHEW CO.,,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

ITA 48/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

THE ACIT, CIR-1(1), KOCHI, KOCHI vs. SRI.PRINCE JOSEPH, KOCHI

In the result, the appeal filed by the Revenue is dismissed

ITA 272/COCH/2018[2010-11]Status: DisposedITAT Cochin14 Sept 2018AY 2010-11

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt.A.S.BindhuFor Respondent: Sri.Mathew Joseph
Section 143(3)Section 148Section 2(47)

1)/CIT(A)-II/17-18 dated 21- 03-2018, is opposed to law, facts and circumstances of the case. 2. Whether the learned Commissioner of Income Tax (Appeals) was right in allowing the assessee's appeal by applying the ratio of Hon'ble Supreme Court Judgement in the case of CIT Vs Balbir Singh Maini. In the quoted case, the joint

SRI.JOSE THOMAS,ADOOR vs. THE DCIT, CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

ITA 31/COCH/2019[2009-10]Status: DisposedITAT Cochin30 Sept 2019AY 2009-10

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

price of Contract Donation Total Rubber estate Receipts AY 2009-10 1,57,62,060 34,00,000 1,91,62,060 AY 2010-11 4,50,00,000 4,50,00,000 AY 2011-12 8,00,00,000 Jose Thomas

CARMEL EDUCATIONAL TRUST,PATHANAMTHITTA vs. DCIT,CEN- CIRCLE,, KOTTAYAM

In the result, the appeals of the assesses in ITA no

ITA 308/COCH/2019[2008-09]Status: DisposedITAT Cochin30 Sept 2019AY 2008-09

Bench: S/Shri Chandra Poojari, Am & George George K., Jm

price of Contract Donation Total Rubber estate Receipts AY 2009-10 1,57,62,060 34,00,000 1,91,62,060 AY 2010-11 4,50,00,000 4,50,00,000 AY 2011-12 8,00,00,000 Jose Thomas